MoCRA? What is it?

By now you may have heard about the new FDA law that regulates cosmetics. The Modernization of Cosmetic Regulation Act of 2022, or MoCRA, is the most significant expansion of regulations into the cosmetic industry since the expansion of the FDA to include cosmetics in 1938. The benefit to emu farmers who also sell emu oil and emu oil products is that it will require a few extra steps to ensure the safety of the consumer.  In most cases that includes registration of their products and in some cases a registration of your facility with the FDA for Cosmetics. It all depends on your level of involvement in the supply chain.  If you are a farmer, who sells emu fat, but you don’t produce or sell any products, you do not have to do anything.  If you are a consumer of emu oil products, rest assured that you are now consuming safer products.  If you simply sell emu oil products under someone else’s label, and your company name is not on it, you don’t need to do anything.  If you sell products under your name or company name you are a distributor and you must register your product with the FDA, but you are not required to register your facility.  If you make, repackage, or change the product in any way, you are a manufacturer and you must register your facility and your product with the FDA.  That last category is a little more involved and I suggest reading up on the FDA regulations for cosmetic manufacturers. 


  1. Matt Gulick on July 26, 2023 at 6:55 pm

    This killed our Artisan Emu Oil Soap products.
    They are made by our daughter, of high quality products. She is supper sensitive to fragrances and various ingredients used in soap making. All of her recipes use only the highest quality products from reputable sources.

    The requirements placed on her production are egregious and, given all of the requirements, it is not possible for her to comply. As such, she will no longer be making soaps.

    It’s sad that government regulations only benefit corporate America and put a choke hold on small business.

    Everything now costs more and regulations are getting bloated to the point of smothering small business. And, since January of 2021, it has getting exponentially worse.

    All of these things combined have made our continued ability to be engaged in Emu Farming, nearly impossible.

  2. Joylene Reavis on August 19, 2023 at 12:05 pm

    Will the changes to the Cosmetic Act affect soapmaking?

  3. Joylene Reavis on August 19, 2023 at 12:07 pm

    Can I sell another company’s brand without registering even though my oil is in it?

    • Caleb Binford on October 5, 2023 at 9:24 am

      Short answer is yes. If you are selling another companies brand, and your name is not listed as the responsible party, then you are not required to register that product. So if your name is not on the “manufactured for” or “distributed by” section of your label, then you are not required to register that product, the manufacturer is.

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